20240829Staff 113-119 to IPC (Redacted).pdf

RECEIVED
Thursday, August 29, 2024 3:01:29 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS )
ASSOCIATED WITH INCREMENTAL ) REDACTED FOURTEENTH
CAPITAL INVESTMENTS AND CERTAIN ) PRODUCTION REQUEST OF
ONGOING OPERATIONS AND ) THE COMMISSION STAFF
MAINTENANCE EXPENSES ) TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY, SEPTEMBER 12, 2024.1
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0314.
14th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 29, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 113: In the Company's Confidential Attachment`
"provided in response to Production Request No. 21(a),
details there was fire damage to existing poles. Please explain if the Company received any funds
from insurance for the damaged poles. If so, please provide the amount that was received by
insurance and explain how it was applied to the total project cost.
REQUEST NO. 114: If any proceeds from insurance claims were received for any
damages or repairs that involved capitalized plant or initiated additional capital expenditures,
please provide the associated capital project and accounting treatment.
REQUEST NO. 115: Please provide the following information associated with the
components (e.g., Capacitor Bank, Control System Building, and Construction) of Budget ID
a. The actual in-service date for each individual component of the project.
b. A breaking down of the total actual cost of the project, first by Idaho Power and joint
owner, PacifiCorp, then for each component and finally by cost category (materials,
purchased services, AFUDC, overheads, etc.) in workpapers with formulas intact.
c. Please reconcile the project budget against the following:
i. Response to Request No. 22(e) -Variance Notes:—; and
ii. Response to Request No. 17(a)—Confidential Attachment 2:
d. Please reconcile the following actual costs against the following:
i. Second Supplemental Response to Staff s Request No. 5 - Confidential
Attachment- Capital Projects Completed Thru June 2024: $—; and
ii. Response to Request No. 17(a)—Confidential Attachment 2:
14th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 29, 2024

REQUEST NO. 116: Please provide the following information for Budget ID
project referenced in the Second
Supplemental Response to Staff s Request No. 5 - Confidential Attachment. Please include any
available workpapers with formulas intact. If any of the information requested below cannot be
provided or is not available,please explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the Work-Breakdown Structure
("WBS"); and
iii. Contractor change orders.
c. If a Request for Proposal ("RFP") or Request for Quote ("RFQ") was submitted,
please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
d. Please provide the following related to completion of the project:
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and
iii. Budget update information throughout the timeline of the project including the
original approved budget.
REQUEST NO. 117: Please provide the following information for Budget ID
project referenced in the Second
Supplemental Response to Staffs Request No. 5 - Confidential Attachment. Please include any
available workpapers with formulas intact. If any of the information requested below cannot be
provided or is not available,please explain why it is not available or cannot be provided.
14th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 29, 2024

a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the WBS; and
iii. Contractor change orders.
c. If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
d. Please provide the following related to completion of the project:
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and
iii. Budget update information throughout the timeline of the project including the
original approved budget.
REQUEST NO. 118: Please provide the following information for Budget ID
project referenced in the Second Supplemental
Response to Staff s Request No. 5 - Confidential Attachment. Please include any available
workpapers with formulas intact. If any of the information requested below cannot be provided
or is not available, please explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the WBS; and
iii. Contractor change orders.
c. If a RFP or RFQ was submitted, please provide the following information:
14th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 AUGUST 29, 2024

i. A copy of the RFP or RFQ that was submitted;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
d. Please provide the following related to completion of the project:
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and
iii. Budget update information throughout the timeline of the project including the
original approved budget.
REQUEST NO. 119: Please provide the following information for Budget ID
project referenced in the Second
Supplemental Response to Staff s Request No. 5 - Confidential Attachment. Please include any
available workpapers with formulas intact. If any of the information requested below cannot be
provided or is not available,please explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project schedule broken down by the WBS; and
iii. Contractor change orders.
c. If a RFP or RFQ was submitted, please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. The short-list bidder scorecard; and
iii. A copy of the winning bid.
d. Please provide the following related to completion of the project
i. In-service day of the project;
ii. Necessary workpaper with formulas intact for the total actual cost of the
project; and
14th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 AUGUST 29, 2024

iii. Budget update information throughout the timeline of the project including the
original approved budget.
DATED at Boise, Idaho, this 29`h day of August 2024.
k,74- M,
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#14 Redacteddocx
14th PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 AUGUST 29, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS -?-I DAY OF AUGUST 2024,
SERVED THE FOREGOING REDACTED FOURTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-
E-24-07, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: lnordstromAidahopower.com E-MAIL: ttatum(cuidahopower.com
dwalker(&idahopower.com caschenbrenner(cDidahopower.com
mgoicoecheaallenoidahopower.com mlarkinrs�idahopower.com
dockets cuidahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK & OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance(clae isinsi hg t.com
E-MAIL: elo(&echohawk.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreading c-mindspring com
E-MAIL: peterAixichardsonadams.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveld(�idahoconservation.org
PETER MEIER EMILY W MEDLYN
US DEPT OF ENERGY US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585 WASHINGTON DC 20585
E-MAIL: petenmeier(c�-hq.doe.gov E-MAIL: Emily.medlyn(&hq.doe.gov
CERTIFICATE OF SERVICE

JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 KRISTINE A.K. ROACH
E-MAIL: jswier(a)micron.com HOLLAND & HART LLP
555 17T" ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoff cc0ollandhart.com
tnelson(dUllandhart.com
aw j ensen(c�ho l l andhart.com
karoach cchollandhart.com
aclee c't hollandhart.com
[e-mail]
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubblencityofboise.org
E-MAIL: ejewell(cbcityofboise.org
boisecitvattorney qccitvofboise.org
PATRICIA JORDAN, S CRETARY
CERTIFICATE OF SERVICE